River Keeper Report on Hudson River Sewage

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    - CVR-1 -

    Hw Is the Wter?Sewage Contamination in the Hudson River Estuary

    2006 2010

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    Trac Brow, Ator ad Pricipal Researcer

    Jo Lipscomb, Project Desig & Directio

    2011 Rivereeper, Ic.

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    Table o Contents

    How Is the Water? ...................................................................................................... 3

    Riverkeepers Water Quality Study ............................................................................. 9

    Sewage Contamination in the Hudson River ............................................................. 13

    What Now?: Improving Our Water Quality ................................................................ 33

    Appendix I: Waterborne Illnesses and Human Health ................................................ 40

    Appendix II: Other Pollutants in the Hudson River ..................................................... 41

    Appendix III: Federal Guidelines or Enterococcus .................................................... 41Appendix IV: Sampling Site Descriptions .................................................................. 42

    Acknowledgements ................................................................................................. 46

    Endnotes ........................................................................................................... ...... 47

    Cover Photo: Swimming in Sleepy Hollow

    Hw Isthe Wter?

    Sewe Ctiti iThe Hds Rier Estr

    Findings rom

    the Riverkeeper

    Water Quality Study,

    2006-2010

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    Hw Isthe Wter?

    Clockwise rom top let: Swimmers in the Harlem River, in the Hudson at Sleepy Hollow, on the

    Coxsackie waterront, and completing the annual Swim For Lie swim across the Tappan Zee Bay

    The question Riverkeeper is most oten asked when patrolling the Hudson is: How is the water?

    Ater ve years o sampling, our quick answer is: Not nearly good enough.

    Since the late summer o 2006, we have collected approximately 2,000 samples rom 75 set locations

    throughout the 155-mile long estuary. Our water quality study has ound sewage contamination rom

    New York Harbor to above the Troy dam.

    Viewed as a whole, water quality in the Hudson ailed the U.S. Environmental Protection Agency

    (EPA) guidelines or sae swimming 21% o the times we sampled. That is equivalent to 1 days a

    week on average.i

    By comparison, water quality samples collected at beaches nationwide (including ocean, bay and

    Great Lake beaches) ailed the EPA sae swimming standard 7% o the times sampled over the

    same time period. ii

    7%

    21% 10%

    93%

    69%

    U.S.Beaches

    HudsonRiver

    HudsonRiverWaterQualityvs.

    Na=onwideBeachWaterQuality

    Unacceptable PossibleRisk Acceptable

    Figre 1: Hudson River compared with Beaches Nationwide: Percent Samples Unacceptable

    But people dont swim, or kayak, or go tubing, on an average day. They get in the water at a specictime and place. And those places are spread throughout the estuary ar outnumbering the our ocial

    swimming beaches designated in the estuary.

    Our data clearly shows water quality varying widely location by location and day by day. Some o the

    most requently contaminated sites are surprisingly close to some o the least contaminated ones. This

    suggests that there are many sources o sewage contamination and that they can oten be traced to a

    specic local source.

    Local sources can oten be remedied with local solutions.

    Acceptable meets EPA single sample guideline or sae swimming. Unacceptable ails EPA single sample

    guideline or sae swimming. Possible Risk meets EPA single sample guideline but would ail geometric mean

    guideline i sustained over time.

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    Our ndings highlight the need to greatly reduce the amount o sewage entering the Hudson. A

    requency o sewage contamination 3 times the average at beaches nationwide is not acceptable.

    The rst critical step towards cleaner water is to inorm the public about the scale o the problem.

    The strong response to the water quality inormation we share online, in emails and at public meetings

    shows that the public is extremely interested. A large and growing constituency enjoys the river and

    wants to make sure theyre swimming in the cleanest water possible.

    Figre 2: Site Findings: Percent o Samples Unacceptable, Possible Risk and Acc eptable

    3241

    222422

    3528

    6550

    44354741

    18

    6

    6

    1211

    62028

    3021

    186

    6853

    7871

    7853

    61293028

    3532

    4176

    Hudson Launch Ramp

    Athens STP** Outfall

    Gay's Point midchannel

    Coxsackie Waterfront Park

    Coeymans Landing

    Castleton, Vlockie Kill

    Bethlehem Launch Ramp

    Island Creek/Normans Kill

    Dunn Memorial Bridge

    Albany Rowing Dock

    Congress Street Bridge

    Hudson River above Troy Lock

    Mohawk River

    Hudson above Mohawk River

    1210

    50151218

    11

    622

    511

    5048

    291111

    2924

    11621

    3537

    6

    1515

    66

    6

    1132

    1914

    1010

    11

    55

    82

    9035

    708276

    8910094

    7295

    7918

    3357

    8989

    6267

    7894

    796058

    Cold Spring Harbor

    Little Stony Point

    Newburgh Launch Ramp

    Beacon Harbor

    Wappingers Creek

    Marlboro Landing

    Poughkeepsie Launch Ramp

    Pough. drinking water intake

    Norrie Point midchannel

    Norrie Point Yacht Basin

    Port Ewen drinking water intake

    Kingston Point Beach

    Kingston STP** Outfall

    Kingston Public Dock

    Eddyville Anchorage

    Ulster Landing Beach

    Tivoli Landing

    Esopus Creek Entrance

    Esopus Creek West

    Malden Launch Ramp

    Inbocht Bay

    Catskill Launch Ramp

    Catskill Creek, East End

    Catskill Creek, First Bridge

    501313

    3953

    2010513

    3411

    281314

    11710

    88

    71015

    2614

    77

    3426

    398077

    5339

    738080

    8740

    7566

    8052

    74

    Gowanus Canal

    The Battery midchannel

    East River midchannel 23rd St.

    Newtown Creek, Dutch Kills

    Newtown Creek, Metro. Bridge

    East River at Roosevelt Island

    Castle Point, NJ

    Pier 96 Kayak Launch

    79th St. midchannel

    125th St. Pier

    125th St. STP** Outfall

    Harlem River, Willis Ave. Bridge

    GW Bridge midchannel

    Harlem River, Wash. Ave. Bridge

    Dyckman St. Beach

    % Unacceptable % Possible Risk % Acceptable

    446

    5053

    8656

    71523

    10

    310

    244410

    916

    95

    1612

    511

    25

    2614

    710

    10

    7

    215

    9141

    8595

    3435

    933

    9080

    5276

    938780

    10069

    9675

    85

    Yonkers STP** Outfall

    Saw Mill River

    Yonkers midchannel

    Irvington Beach

    Piermont STP** Outfall

    Piermont Pier

    Sparkill Creek

    Tarrytown Marina

    Tappan Zee Bridge midchannel

    Kingsland Pt., Pocantico River

    Nyack Launch Ramp

    Ossining Beach

    Croton Point Beach

    Haverstraw Bay midchannel

    Furnace Brook

    Emeline Beach

    Cedar Pond Brook

    Stony Point midchannel

    Peekskill Riverfront Green Park

    Annesville Creek

    11

    11

    8989

    Fort Montgomery

    West Point STP** Outfall

    * Sparkill Creek is an inland site that is sampled more requently

    ** STP = Sewage Treatment Plant

    Riverkeepers 75 Standard Sampling Sites

    *

    HoW IS THE WaTER?

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    HElpful TERmInology

    Elet: The outowing mixture o

    water and waste rom a treatment plant,sewer, or outall into a body o water.

    Eterococcs (Etero): A sewage

    indicating bacterium that lives in the

    intestines o humans. See Appendix

    III or inormation on how Entero is

    used to assess water quality.

    Geometric mea: A method or

    analyzing bacterial concentrations

    that dampens the eect o very high

    or very low values.

    Patoges: Any disease-causing

    microbe.

    Predictive models: Creating a

    model to predict the probability o

    an outcome.

    Tribtaries (tribs): A stream or river

    that ows into a main stem, or primary

    downstream portion, o a river.

    Tributaries do not ow directly into

    the ocean.

    Trbidit: A measure o thesuspended solids in a solution, and

    an indicator o water quality.

    Microbe/Microorgaism (microbial):

    A microscopic organism, such as a

    bacterium, not easily observed with-

    out the aid o a microscope unless it

    occurs in a large colony consisting o

    many cells.

    Sewage idicator: Any element that

    points to an input o sewage into a

    body o water.

    Wastewater: Water that has been

    mixed with waste due to anthropo-

    genic activity.

    Watersed: The geographical area

    drained by a river and all o its tributaries.

    In this report, we share some o the patterns

    we are seeing in Hudson River water quality,

    highlight examples o sewage contamination,

    and call or specic actions that can help

    clean up the river we love.

    Swibiit

    Clean water has been and always will be an

    issue o great importance to the public. The

    Clean Water Act o 1972 was the result o

    public outrage over declining water quality.

    Since then, investments in our local wastewater

    inrastructure have gone a long way towards

    cleaning up our river. The Hudson River has

    undergone a renaissance as a destination or

    recreation, tourism and water sports.While there are only our ocial swimming

    beaches on the Hudson, a New York State

    survey rom 2000 conrms that the river has

    more than 100 unocial sites.iii From our

    patrol boat we see people in the water along

    all 155 miles rom NY Harbor to Troy.

    So what determines whether water quality is

    sae? There are a number o actors such as cur-

    rents, temperature, underwater hazards, turbidity

    and pollution. One o the most important

    actors is pollution rom raw or partiallytreated sewage, which can carry disease-causing

    pathogens and parasites.

    According to a report rom the Natural

    Resources Deense Council, in 2009

    seventy-our percent o beach closings and

    advisories were due to high levels o sewage

    contamination.iv That number has been rising

    as our population continues to grow and our

    wastewater inrastructure ails to keep pace

    with increasing demand.v

    Each year more than 860 billion gallons oraw or partially treated sewage are dumped into

    U.S. waterways.vi New York City alone dumps

    27 billion gallons o combined sewage and

    wastewater into its harbor each year.vii

    [For inormation on waterborne pathogens and

    their health eects, see Appendix I.]

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    y Ct me Wht y Dt mesre

    There is little testing, or modeling and prediction, or sewage contamination in the Hudson River Estuary.

    Beore Riverkeepers study, there was no regular testing or sewage contamination that crossed

    county lines. While we collect eight samples a year at most stations, thats not requently enough totell the public where and when its sae to swim. Our study has begun to uncover important patterns

    in water quality, but its most important nding may be the need or regular water quality monitoring

    o the Hudson.

    O the ten counties on the estuary, only our test or sewage contamination at their shorelines, and

    that testing is limited in scope and requency.viii None o these report their ndings to the public.

    New York City has been collecting water quality data on New York Harbor since 1909. This record

    shows that over time, investments in NYCs wastewater inrastructure has led to improved water

    quality in New York Harbor. The NYC Department o Environmental Protection (DEP) publishes

    its ndings once a year in the orm o an annual report, but the raw data is not easily available

    and reports are only available ater a delay o a year or two. ix

    Despite this lack o critical data, the Department o Environmental Conservation (DEC) has

    classied Hudson River waters rom north o the Bronx Borough line all the way to the northern

    end o Columbia County as acceptable or swimming.

    The Clean Water Act mandated that the waters o the United States be swimmable and shable by

    1983 and that there be zero discharge o pollutants in our nations waterways by 1985. New York

    State also set clean water goals, including that the Hudson River be swimmable by 2009. When that

    date passed, the state set a new goal or a swimmable Hudson by 2020, except ollowing rainstorms.

    As a nation and as New Yorkers we have ailed terribly to meet these goals. A critical step

    towards eliminating pollution sources is establishing a consistent and appropriate system or

    water quality testing.

    It is very important to set national and local clean water goals. Its more important to achieve them.A critical step towards attaining our water quality goals is establishing a consistent and appropriate

    system or water quality testing. Without water quality data, pollution sources and impacts cannot

    be identied.

    You cant manage what you dont measure.

    [For other Hudson River pollutants see Appendix II.]

    HoW IS THE WaTER?

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    Figre 3: NY State Water Classiication and County Water Quality Testing

    ALBANY

    COUNTY

    NO TESTING

    RENSSELAER

    COUNTY

    NO TESTING

    GREENE COUNTY

    NO TESTING

    COLUMBIACOUNTY

    NO TESTING

    ORANGE COUNTY

    NO TESTING

    COLUMBIA COUNTY

    NO TESTING

    ULSTER

    COUNTY

    TESTINGDUTCHESS

    COUNTY

    TESTING

    ROCKLAND

    COUNTY

    TESTING

    WESTCHESTER

    COUNTY

    TESTING

    NEW YORK CITY

    TESTING

    CLASS C

    Fish propogation, fishing & water sports.

    No swimming allowed.

    CLASS A

    Drinking water, culinary, swimming,

    fish propogation and water sports.

    CLASS B

    Swimming, water sports,

    fish propogation and fishing.

    CLASS SB

    Swimming, water sports,

    fish propogation and fishing.

    CLASS I

    Water sports, fish propogation and fishing.

    No swimming allowed.

    HuDSon RIvER WaTER ClaSSIfICaTIon anD TESTIng

    = Official Swimming Beach

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    RiereeersWter Qit

    Std

    mEaSuRIng SEWagE ConTamInaTIon

    Riverkeeper tests or the sewage-indicating microbe o the genus Enterococcus (Entero).It is the only group o microbes recommended by the Environmental Protection Agency (EPA)

    or use as sewage indicators in both salt and resh water - the Hudson River contains salt,

    resh and brackish (mixed) water.

    Te EPA describes Etero i its testig gidelies as ollows:

    Enterococciare commonly ound in the eces o humans and other warm-

    blooded animals. The presence oEnterococciin water is an indication o ecal

    pollution and the possible presence o (pathogens ound in intestines). xi

    We have based our assessment o water quality on the EPA ederal guidelines outlined in the

    2000 Beaches Environmental Assessment and Coastal Health (BEACH) Act. xii

    [See Federal Guidelines or Enterococcus in Appendix III]

    Clockwise rom top let: Sampling water quality rom the Riverkeeper patrol boat, Andy Juhl,

    Carol Knudson, Greg OMullan and John Lipscomb

    Riverkeeper started the Water Quality Program in 2006, its primary goal testing or sewage contamina-

    tion. Other important variables that relate to water quality, such as temperature, salinity, turbidity and

    chlorophyll and oxygen concentrations are also measured.

    Or Sciece Parters

    This project is conducted in collaboration with scientists rom Columbia Universitys Lamont-Doherty

    Earth Observatory and Queens College, City University o New York. Our Co-Principal Investigators,

    Gregory OMullan, Ph.D. and Andrew Juhl, Ph.D., contribute their expertise in environmental microbiol-

    ogy and oceanography to the project. They developed our testing protocol and oversee our eld sampling,

    environmental sensor measurements and microbiological analyses.x

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    In 2006 and 2007 Riverkeeper sampled sites rom NY Harbor to Peekskill. In 2008 we expanded the

    study north to Troy. We now sample at 75 set locations, once a month, rom May through October.

    The Riverkeeper patrol boat, R. Ian Fletcher, is equipped with a mobile lab that allows us to collect,process and incubate the samples onboard.

    Our sites all into our categories near-shore, mid-channel, tributaries, and wastewater treatment

    plant outalls.

    [See Appendix IV or a list o our regular sampling sites with descriptions. In addition to the sites

    listed, we conduct exploratory sampling at a variety o locations to investigate specic events and

    problem areas.] xiii

    Figre 4: Riverkeepers 75 Standard Sampling Sites

    = 75 standard sampling sites = County lines = the Hudson River watershed

    RIVERkEEPERSWATER QuALITyTESTInG SITES

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    Shri Dt with the pbic

    To distribute our water quality data to the public we have created an online database at

    www.riverkeeper.org/water-quality/locations that is updated within days o our monthly sampling

    patrols. We also publish a monthly Water Quality Report based on each sampling patrol that is

    available as an e-letter. In addition to online publishing, we oer live presentations about our water

    quality ndings that have been given at conerences, at community events and to agencies involved

    in water quality management.

    A sampling site page rom Riverkeepers online water quality database: www.riverkeeper.org/water-quality/locations

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    Riverkeeper has processed more than 2,000 water quality samples rom the Hudson River since 2006.Based on that number o samples, and the expert analyses o our science partners, we are now able

    to start identiying patterns o sewage contamination in the Hudson River. Although we have ound

    evidence o sewage contamination at every one o our 75 testing locations, the levels o contamination

    vary enormously over time and by location.

    Overall our 75 sampling sites had unacceptable water quality 21% o the times that we tested, which is

    equivalent to 1 days a week on average.

    SeweCtiti

    i theHds Rier

    Clockwise rom top let: Combined Sewer Overlow (CSO) in Troy, loatables and sewage in the Hudson,

    Combined Sewer Overlow (CSO) in New York City, Separate Sewer Overlow (SSO) at the Nyack waterront

    WaTER QualITy aSSESSmEnT

    Riverkeepers water quality assessment is based on EPA guidelines or sae swimming.

    accetbe samples meet the EPA single sample guideline.uccetbesamples ail the EPA single sample guideline.pssibe Rissamples meet the EPA single sample guideline but i

    sustained over time they would ail the EPA geometric

    mean guideline.

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    Unortunately there were 10 other sites that had unacceptable counts 50%, or more, o the times

    we sampled.

    Each group contains sites rom dierent regions o the Hudson. Some o the cleanest sites we

    ound are surprisingly near some o the most contaminated sites, such as the Tarrytown Marina

    and Irvington Beach.

    10 WoRST loCaTIonS

    with unacceptable Entero counts at least 50% o the times sampled 06-10

    Gowanus Canal, Brooklyn - 50%

    Newtown Creek, Metropolitan Ave. Bridge, Brooklyn - 53%

    Sparkill Creek, Sparkill - 86%

    Sewage Treatment Plant Outalls at Piermont - 50%

    Piermont Pier, Piermont - 50%

    *Tarrytown Marina, Tarrytown - 56%

    Newburgh Launch Ramp, Newburgh - 50%

    Kingston Wastewater Sewage Treatment Plant Outall, Kingston - 50%

    *Island Creek/Normans Kill, Glenmont - 65%

    Dunn Memorial Bridge, Albany - 50%

    *These sites were added to the study in 2008 and thereore have a smaller number o samples

    (we sampled Tarrytown Marina 9 times and Island Creek/Normans Kill 17).

    7 BEST loCaTIonS

    with unacceptable Entero counts 0% o the times sampled 06-10

    Dyckman Street, Manhattan

    Yonkers Wastewater Treatment Plant Outall, Yonkers

    Irvington Beach, Irvington

    Croton Point Beach, Croton-on-Hudson

    Emeline Beach, Haverstraw

    Fort Montgomery, Highlands

    Poughkeepsie Drinking Water Intake, Poughkeepsie

    Through 2006-2010, there were 7 sites where we never collected an unacceptable sample.

    HoW IS THE WaTER?

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    Figre 6: Tappan Zee Bay Sampling Sites

    Sewe Icts are lcized

    One o our most signicant ndings is the high variability o water quality throughout the estuary.

    At locations within a quarter mile o each other, we ound very dierent levels o sewage contamination

    on the same day. In most o the river, weve ound sites that are requently acceptable as well as sitesthat fuctuate between acceptable and unacceptable. Usually the poor water quality at one site is not

    evident at other nearby sites.

    Take or example the Tappan Zee Bay

    water between the shores o Rockland

    and Westchester County. On a wet

    day in October 2010, the Entero counts

    in and along the Bay varied rom an

    acceptable low o less than 10/100 ml

    to an unacceptable high o greater than

    24,200/100 ml (the upper limit o our

    testing ability or a dilution sample).xiv

    That day the highly contaminated water

    on the eastern shore in the Tarrytown

    Marina was not aecting the Tappan Zee

    mid-channel site only one mile away,

    or Kingsland Point Park, one mile to

    the north. The Irvington Beach site, 2.5

    miles to the south was also acceptable.

    The sewage contamination we ound at

    the Nyack Launch Ramp on the western

    shoreline was also localized, while

    Piermont Pier, 3.5 miles south o

    Nyack, was acceptable.

    Table 2: Highly Variable by Location, Example, Tappan Zee Bay

    nac

    Lac Ramp

    Tappa Zee

    mid-caelkigsladPoit Par

    Tarrtow

    Maria

    Irvigto Beac

    STP Otall

    at PiermotSparill

    Cree

    Piermot Pier

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    Figre 7 Poughkeepsie Area Sampling SitesWide and deep sections o the river, like

    Tappan Zee Bay and NY Harbor, have

    greater dilution and mixing or clearing

    up sewage hot spots. However, even in

    locations where the river is narrower we

    still see sewage contamination tending

    to stay localized at the shoreline.

    For example around Poughkeepsie

    on the same October 2010 patrol, the

    Entero count went rom a low o 7/100

    ml to a high o 2420/100 ml (the upper

    limit o our testing ability or an un-

    diluted sample xv) within a nine mile

    stretch o river.

    These examples and others like themshow that the Hudsons sewage contam-

    ination is typically a local problem. The

    good news it that once these sources are

    identied, they can oten be remedied

    with local solutions.

    Communities that invest in clean

    water can produce direct water quality

    improvements.

    RiverMile SiteName SampleDateEnterococcus

    CountQuality

    66.5 WappingersCreek October15,2010 22 Acceptable

    68 MarlboroLanding October15,2010 >2420 Unacceptable

    75Poughkeepsie

    LaunchRampOctober15,2010 78 Unacceptable

    77

    Poughkeepsie

    DrinkingWater

    Intake

    October15,2010 7 Acceptable

    Table 3: Highly Variable by Location, Example, Poughkeepsie Area

    Pogeepsie

    Driig Water Itae

    Pogeepsie

    Lac Ramp

    Marlboro Ladig

    Wappigers Cee

    HoW IS THE WaTER?

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    34%

    25%

    24%

    16%

    9%

    15%

    11%

    7%

    57%

    60%

    65%

    77%

    Tributaries

    STPOu.alls

    Near-shore

    Mid-channel

    TypesofSamplingSites

    Unacceptable PossibleRisk Acceptable

    Figre 8: Percent Acceptable by Type o Sampling Site

    Ctiti Is Hihest t the Shreie d ner Tribtries

    To better understand patterns o sewage contamination we have grouped our sampling sites into our

    location categories:

    1) Mid-channel sites

    2) Near-shore sites

    3) Tributaries (sites where a stream, creek or brook joins the Hudson) xvi

    4) Sewage Treatment Plant (STP) outalls.

    When we view the percent o unacceptable samples by type o location we nd the mid-channel sites

    were the least contaminated category. This isnt surprising given that the sources o sewage are typically

    at the shorelines. The mid-channel also tends to be the deepest and astest moving part o the river so

    dilution, mixing and the sel-fushing power o our tidal river have the greatest impact here.

    Sewage Treatment Plant (STP) outalls, where the partially treated wastewater rom the plant enters

    the river, are on average more requently unacceptable than the ull system. But this doesnt tell the ull

    story because we get a wide variety o results at the STP outalls where we test. Some o the outalls, like

    ones at Kingston and the combined Orangetown and South Rockland County STP outalls at Piermont

    Pier, have a lot o variability in test results, ranging rom acceptable single digit Entero counts to highs

    exceeding the upper limit o our testing system.

    Other plants, like Yonkers and 125th Street in Manhattan, have consistently low Entero counts at their

    outalls however the inrastructure that eeds these and other plants oten ails to get the sewage to the

    plant, especially during wet weather. Combined Sewer Overfows (CSOs), Sanitary Sewer Overfows

    (SSOs) and inrastructure breaks are some other ways in which sewage treatment plants ail to properly

    treat the sewage in their systems.

    [You can read more about our sewer inrastructure in the What Now section.]

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    Figre 9: Tributary Sampling Sites

    55%

    12%

    34%

    8%

    10%

    9%

    37%

    78%

    57%

    WETONLY:

    DRYONLY:

    COMBINEDWET+DRY

    TributarySites

    U nacceptable Possible Risk Acceptable

    Figre 10: Wet Weather Impact on Tributary Water Quality

    Wet weather is classiied as more than 0.25 inches o rain

    in the three days prior to sampling.

    Water quality at the near-shore sites is not

    as good as mid-channel or as the ull sys-

    tem. This is because the shoreline is where

    the people are and where the sewage

    typically enters the river. As mentioned

    earlier, we nd acceptable water quality at

    many o these sites a vast majority o the

    time and at some sites every time we have

    sampled. However, some o these sites are

    very heavily sewage laden at times and

    others have a consistent low-level sewage

    signal whenever we test. You can see the

    variable near-shore ndings in Figure 2

    and on the Regional Maps.

    The unexpected bad news is the high re-

    quency o sewage contamination entering

    the Hudson rom our tributaries (tribs).

    Our study contains 15 standard tributary

    sites; most are located at the mouth o the

    trib where the tributary fow enters the

    main stem o the Hudson.

    These tributary sites were unacceptable

    34% o the times we sampled, or the

    equivalent o 2 days a week on average.

    We have ound that some streams and

    brooks in our communities can be chronic

    sources o sewage contamination meaningthat they are a source o sewage contami-

    nation or the shoreline and the river no

    matter what the weather. When it rains,

    even more sewage enters the Hudson rom

    tributaries. Our study ound a ourold

    increase in the requency o unacceptable

    samples at our tributary sites ater wet

    weather.

    TRIBuTARIES OF ThE huDSOn

    WhERE WE SAMPLE:

    Gowas Caal Brooklyn

    newtow Cree Dutch Kills Brooklynnewtow Cree Metropolitan Ave. Bridge

    Brooklyn

    Pocatico River Kingsland Point Park

    Sleepy Hollow

    Frace Broo Cortlandt

    Cedar Pod Broo Stony PointAesville Cree Peekskill

    Rodot Cree Kingston Public Dock Kingston

    Rodot Cree Eddyville Anchorage Eddyville

    Esops Cree entrance Saugerties

    Esops Cree west Saugerties

    Catsill Cree launch ramp Catskill

    Catsill Cree east end Catskill

    Catsill Cree First Bridge Catskill

    Islad Cree/normas kill Glenmont

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    32%

    9%

    21%

    11%

    9%

    10%

    57%

    82%

    69%

    WETONLY:

    DRYONLY:

    COMBINEDWET+DRY

    HudsonRiverEstuary:75SamplingSites

    Figre 11: Impact o rain on percent o unacceptable samples,

    averaged across all sites

    The pattern we nd is consistent with a recent water quality study in the Albany Pool section o the

    Hudson. In that study, ve tributaries were sampled and their water quality rated using a geometric

    mean. All ailed to meet the geometric mean guideline in wet weather. In dry weather, three o the

    ve ailed, and all had at least one sample that ailed to meet the EPA single sample guideline.xvii

    So what is happening in our community streams, brooks and creeks? Individual tributary studies are

    needed to answer this question and the answers will likely vary somewhat by waterway and watershed.

    Sewage could be entering our local waters rom any number o sources including contaminated ground-

    water rom leaking septic systems and chronic leaks rom sewer pipes; illegal sewage hook-ups; or

    agricultural sources. In wet weather add to that list contaminated overfowing sewer systems.

    [See What are Sanitary Sewer Overfows? on page 21].

    The next phase o Riverkeepers Water Quality Study includes looking more closely at contamination

    in our tributaries. We are partnering with the public on sewage mini-studies on Sparkill Creek, the

    Pocantico River, Esopus Creek, Catskill Creek and Stockport Creek. Our preliminary sampling is

    nding some very high Entero counts in wet weather and intermittent high counts in dry weather.

    [You can read about our tributary studies in the What Now section.]

    Wet Wether Sies:

    The Ri Cecti

    During and shortly ater rainall

    the requency o unacceptable

    Entero counts increases in all the

    regions and at all the types o sites

    where we sample, but not at every

    individual location. Overall the

    percent o samples that wereunacceptable increased rom 9%

    in dry weather to 32% in wet

    weather a threeold increase.

    There are several sources that

    can contribute to rain-related

    sewage contamination. One

    contributor is contaminated

    groundwater entering streams,

    brooks and rivers. Another actor

    is rain-triggered overfows rom

    our sewage inrastructure. Theseoverfows all into two categories -

    Combined Sewer Overfows (CSOs),

    which happen by design, and

    Sanitary Sewer Overfows (SSOs),

    which are the result o aulty or

    overloaded sewer systems.

    Wet weather is classied as more than 0.25 inches o rain

    in the three days prior to sampling.

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    Figre 12: What Are Combined Sewer Overlows (CSOs)

    WHaT aRE ComBInED SEWER ovERfloWS (CSos)?

    CSOs are remnants o the countrys early inrastructure. In the past, communities built sewer systems

    to collect both stormwater runo and sanitary sewage in the same pipe. During dry weather, these

    combined sewer systems transport wastewater directly to the sewage treatment plant. In periods

    o rainall or snowmelt, however, the wastewater volume in a combined sewer system can exceed

    the capacity o the sewer system or treatment plant. For this reason, combined sewer systems are

    designed to overfow occasionally and discharge excess wastewater directly to nearby streams,

    rivers, lakes, or estuaries. Combined sewer overfows (CSOs) contain not only stormwater but also

    untreated human and industrial waste, toxic materials, and debris. This is a major water pollution

    concern or cities with combined sewer systems. CSOs are among the major sources responsible or

    beach closings, shellshing restrictions, and other water body impairments.

    - U.S. Environmental Protection Agency

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    Figre 13: What Are Sanitary Sewer Overlows (SSOs)

    WHaT aRE SanITaRy SEWER ovERfloWS (SSos)?

    Properly designed, operated, and maintained sanitary sewer systems are meant to collect and

    transport all o the sewage that fows into them to a publicly owned treatment works (STP). However,

    occasional unintentional discharges o raw sewage rom municipal sanitary sewers occur in almost

    every system. These types o discharges are called sanitary sewer overfows. SSOs have a variety

    o causes, including but not limited to blockages, line breaks, sewer deects that allow storm water

    and groundwater to overload the system, lapses in sewer system operation and maintenance, power

    ailures, inadequate sewer design and vandalism.

    - U.S. Environmental Protection Agency

    Together these rain-triggered overfows dump tens o billions o gallons o combined sewage and

    stormwater into the Hudson River each year. In some communities, like New York City, as little as

    inch o rain can trigger an overfow.

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    Table 4: Variable Over Time: Wet Weather Examples

    Figre 14: Catskill Launch Ramp and Catskill CreekWter Qit C vr gret

    t Sie lcti

    Weve ound many examples o locations that

    have a high variability in sewage contaminationdue to wet weather.

    One example is the Catskill Launch Ramp

    located just north o Catskill Creek. The water

    quality there varies rom acceptable single digit

    Entero counts to highs in the hundreds, with

    one exceeding 2,420/100 ml.xviii

    When you view the sewage contamination

    spikes at this site along with the more requently

    contaminated Catskill Creek you can see that

    when it rains the Creek brings contaminated

    water into the Hudson and as a result waterquality at the launch ramp fuctuates greatly.

    CatskillCreekEastEnd CatskillLaunchRamp

    SampleDateCumula8veRain

    3daysprior(in.)EnteroCount WaterQuality EnteroCount WaterQuality

    22-May-08 0.19 15 Acceptable 1 Acceptable

    18-Jun-08 1.07 12 Acceptable 9 Acceptable

    17-Jul-08 0.11 3 Acceptable 6 Acceptable

    9-Aug-08 1.48 197 Unacceptable 23 Acceptable

    16-Sep-08 0.34 1 Acceptable 4 Acceptable

    23-Oct-08 0.23 10 Acceptable 4 Acceptable

    15-May-09 0.51 4 Acceptable 3 Acceptable

    12-Jun-09 1.15 387 Unacceptable 29 Acceptable

    31-Jul-09 1.88 1986 Unacceptable >2420 Unacceptable

    24-Aug-09 2.78 >2420 Unacceptable 488 Unacceptable

    17-Sep-09 0 14 Acceptable 16 Acceptable

    23-Oct-09 0 12 Acceptable 3 Acceptable

    25-May-10 0 4 Acceptable 2 Acceptable

    18-Jun-10 0.25 261 Unacceptable 6 Acceptable

    19-Jul-10 0.66 4 Acceptable 2 Acceptable

    21-Aug-10 0.21 51 PossibleRisk 8 Acceptable

    23-Aug-10 0.48 >2420 Unacceptable 435 Unacceptable

    14-Sep-10 0 21 Acceptable 31 Acceptable

    16-Oct-10 1.28 1986 Unacceptable 192 Unacceptable

    Catsill Cree

    First Bridge Catsill Cree

    Lac Ramp

    Catsill Cree

    East Ed

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    There are also sites where we nd highly variable water quality thats not connected solely with

    wet weather.

    The Newburgh Launch Ramp, another popular spot or public access, is located next to a CSO pipe

    and a ew hundred yards south o a sewage treatment plant outall. This site has single digit, and thusacceptable counts, but there are still many counts in the hundreds, and even one greater than 2420

    count. There are unacceptable samples on dry days and acceptable ones on wet. Across the river in the

    Beacon Harbor we nd better water quality overall (lower high counts and ewer o them) but still rain

    is not the only actor.

    Table 5: Variable Over Time: Dry Weather Examples

    NewburghLaunchRamp BeaconHarbor

    SampleDate Cumula9veRain3daysprior(in.)

    EnteroCount

    WaterQuality EnteroCount

    WaterQuality

    21-May-08 0.18 19 Acceptable 3 Acceptable

    17-Jun-08 1 41 PossibleRisk 17 Acceptable

    16-Jul-08 0.64 10 Acceptable 1 Acceptable

    6-Aug-08 0.28 27 Acceptable 4 Acceptable

    20-Sep-08 0 1 Acceptable 3 Acceptable

    22-Oct-08 0.02 19 Acceptable 22 Acceptable

    14-May-09 0.06 2 Acceptable 6 Acceptable

    9-Jun-09 0.93 1046 Unacceptable 104 Unacceptable

    30-Jul-09 0.54 225 Unacceptable 12 Acceptable

    3-Aug-09 1.7 115 Unacceptable 8 Acceptable

    22-Aug-09 0.58 687 Unacceptable 8 Acceptable

    16-Sep-09 0.01 36 PossibleRisk 23 Acceptable

    21-Oct-09 0.18 184 Unacceptable 107 Unacceptable

    23-May-10 0 41 PossibleRisk 7 Acceptable

    17-Jun-10 0.02 225 Unacceptable 50 PossibleRisk

    20-Jul-10 0.03 1300 Unacceptable 28 Acceptable

    19-Aug-10 0.96 328 Unacceptable 48 PossibleRisk

    13-Sep-10 0 17 Acceptable 20 Acceptable

    14-Oct-10 0.34 326 Unacceptable 56 PossibleRisk

    15-Oct-10 1.45 >2420 Unacceptable 816 Unacceptable

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    fr Rei views

    For a regional perspective we have divided our sampling sites into our geographic groups New York

    City, Westchester-Rockland, Bear Mountain to Catskill and the Albany Region. All our regions suer

    rom intermittent sewage contamination but to varying degrees.

    The northernmost and southernmost regions, each dened by a major waterront city, had lower water

    quality overall compared with the predominantly suburban and rural areas in between. However it may

    surprise some to see New York City, with 8 million residents, achieving better water quality than the

    Albany region which has closer to 1 million. Read A Tale o Two Cities on page 30 to get a better

    understanding o the actors infuencing these results.

    It was also unexpected to nd the more densely populated Westchester and Rockland County region

    had lower sewage contamination levels than the more sparsely populated region to the north that spans

    rom Bear Mountain Bridge to Catskill. Based on our preliminary ndings we believe this dierence

    may be attributed to the higher number o tributaries in the Bear Mountain-Catskill region. Our study

    ndings indicate that these tribs increase contamination at the near-shore sites in their vicinity including

    high spikes in wet weather.

    When we view the data categorized as wet weather and dry weather samples, the picture or each

    region becomes clearer. Its important to note that all regions include some older towns and cities with

    combined sewer systems and CSOs however the volume o combined stormwater and sewage that each

    releases varies greatly.

    New York City has the best water quality in dry weather o all our regions but sewage contamination

    increases veold when it rains. It has a big CSO problem 480 CSO pipes discharging 27 billion gal-

    lons o combined sewage and stormwater into its surrounding waters each year.

    Bear Mountain-Catskill region has a surprisingly similar weather-to-sewage pattern to NYC. It has a

    rain problem too, but its cannot be blamed on a giant CSO system.

    36%

    20%

    15%

    21%

    12%

    7%

    10%

    11%

    52%

    73%

    75%

    68%

    AlbanyRegion

    BearMountain-Catskill

    Westchester-Rockland

    NewYorkCity

    RegionsoftheHudsonRiverEstuary

    U na cc ep ta bl e P os si bl e Ri sk A cc ep ta bl e

    Figre 15: Findings by Region: Percent Acceptable,

    Possible Risk and Unacceptable

    Westchester-Rockland has the

    lowest variability between dry

    and wet weather conditions o

    all the regions with a doubling

    o unacceptable water quality

    counts ollowing wet weather.

    This relatively low wet weather

    spike accounts or Westchester-

    Rockland having the best over-

    all percent acceptable 75%.

    But there is also a lot o vari-

    ability in this region. Remember

    it is home to 4 o the best sites in

    our study and 3 o the worst.

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    30%

    6%

    21%

    15%

    6%

    11%

    56%

    88%

    68%

    WETONLY:

    DRYONLY:

    COMBINEDWET+DRY

    NewYorkCityRegion

    22%

    10%

    15%

    9%

    11%

    10%

    70%

    79%

    75%

    WETONLY:

    DRYONLY:

    COMBINEDWET+DRY

    Westchester-RocklandRegion

    31%

    9%

    20%

    8%

    7%

    7%

    61%

    84%

    73%

    WETONLY:

    DRYONLY:

    COMBINEDWET+DRY

    BearMountaintoCatskillRegion

    56%

    12%

    36%

    14%

    10%

    12%

    30%

    78%

    52%

    WETONLY:

    DRYONLY:

    COMBINEDWET+DRY

    AlbanyRegion

    Figre 16: Weather Impacts by Region

    RIvERkEEpER

    Wet weather is classied as more than 0.25 inches o rain

    in the three days prior to sampling.

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    1413

    12

    10

    11

    9

    8

    7

    6

    4

    5

    3

    2

    1

    15

    SITE NAME PERCENTAGES MAX. COUNT MIN. COUN

    % Unacceptable % Possible Risk % Acceptable

    50

    13

    13

    39

    53

    20

    10

    5

    13

    34

    11

    28

    13

    14

    11

    7

    10

    8

    8

    7

    10

    15

    26

    14

    7

    7

    34

    26

    39

    80

    77

    53

    39

    73

    80

    80

    87

    40

    75

    66

    80

    52

    74 79

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    44

    6

    50

    53

    86

    56

    7

    15

    23

    10

    3

    10

    24

    4

    4

    10

    9

    16

    9

    5

    16

    12

    5

    11

    2

    5

    26

    14

    7

    10

    10

    7

    21

    5

    91

    41

    85

    95

    34

    35

    9

    33

    90

    80

    52

    76

    93

    87

    80

    100

    69

    96

    75

    85

    SITE NAME PERCENTAGES MAX. COUNT MIN. COUNT

    365

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    57

    58

    59

    60 61

    5556

    54

    53

    4950

    51

    5248

    4746

    45

    44

    43

    42

    4140

    39

    38

    37

    36

    SITE NAME PERCENTAGES MAX. COUNT MIN. COUNT

    >2420 1

    >2420 1

    >2420 1

    >2420 1

    1986 2

    >2420 2420 2

    >2420 2420 2420 1

    >2420 6

    >2420 4

    147

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    74

    71

    69

    68

    67

    66

    65

    63

    73

    72

    70

    64

    62

    75

    SITE NAME PERCENTAGES MAX. COUNT MIN. COUNT

    % Unacceptable % Possible Risk % Acceptable

    >2420 2420 8

    >2420 4

    >2420 7

    >2420 3

    >2420 6

    >2420 2

    1120 1

    770 1

    770 2420 1

    >2420 5

    >2420 4

    75. Hudson above Mohawk River

    74. Mohawk River

    73. Hudson River above Troy Lock

    72. Congress Street Bridge

    71. Albany Rowing Dock

    70. Dunn Memorial Bridge

    69. Island Creek/Normans Kill

    68. Bethlehem Launch Ramp

    67. Castleton, Vlockie Kill

    66. Coeymans Landing

    65. Coxsackie Waterfront Park

    64. Gays Point midchannel

    63. Athens STP Outfall

    62. Hudson Landing Ramp 32

    41

    22

    24

    22

    35

    28

    65

    50

    44

    35

    47

    41

    18

    6

    6

    12

    11

    6

    20

    28

    30

    21

    18

    6

    68

    53

    78

    71

    78

    53

    61

    29

    30

    28

    35

    32

    41

    76

    Rei 4: ab Rei

    (Hudson Launch Ramp to the Mohawk River)

    Max. Count = the highest Enterococcus count we recorded at this site 08 10

    Min. Count = the lowest Enterococcuscount we recorded at this site 08 10

    - 29 -

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    The Capital District at the northern end o

    our study is a dierent story. The Capital

    District includes the city o Albany and parts

    o Rensselaer, Saratoga, Schenectady and

    Albany Counties. This area has 92 CSOs that

    dump an estimated 1.2 billion gallons o

    combined sewage and wastewater into the

    Hudson each year. xxi That mix is entering a

    narrower and shallower section o the Hudson

    River, without the volume and mixing benets

    o close proximity to the Atlantic Ocean that

    NYC enjoys.

    Another important dierence between Albany

    and NYC is that the three sewage treatment

    plants serving the Capital District do not use

    disinection. So in the Capital District the rain-

    triggered CSOs provide a spike o contamination

    on top o a chronically sewage-laden section

    o the estuary.

    The Clean Water Act requires disinection

    at sewage treatment plants (STPs), but by issuing

    special permits (called SPDES), New York

    State has allowed Albany to stay out o compli-

    ance or almost 40 years. The lack o disinection

    at the STPs is one reason Albanys water quality in

    all weather is worse than New York City though

    the latter is a giant metropolis with ar greater

    sewage and CSO volumes.

    In recent years the New York State DEC

    nally required the Capital District to develop

    a Long Term Control Plan or its CSOs. The plan

    currently under development includes adding

    seasonal disinection at the three sewage treatment

    plants in this region a step in the right direction

    or water quality in the Capital District.

    Rowing in Albany

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    Wht nw?Iri or

    Wter Qit

    Clockwise rom top let: Beautiul day at the beach in Sleepy Hollow, citizens investigating a sewage overlow in

    the Saw Mill River, summer un at the Palisades Boat Club, swimming up north near Castleton

    freqet mitri d ntiicti

    New Yorkers are getting into the Hudson River with increasing requency each year however only our

    counties on the river, plus NYC, test Hudson River water quality. O those testing, only the NYC DEP

    publishes their water quality data, which is included in the annual New York Harbor Water Quality

    Report, typically released one to two years ater collection. The report shows patterns in water qualityusing geometric means but does not share the single sample data that allows the variability o sites to

    be easily evaluated. xxii

    When you ask the people swimming at the many access points along the river i the water is sae or swimming

    you will oten hear I it wasnt sae they wouldnt let us swim in it. Getting in the water based on this

    alse assumption is putting the public at risk o contracting any number o waterborne illnesses, some with

    serious long-term health consequences.

    People who enjoy swimming in the Hudson River deserve the same protection rom their local Department

    o Health as their neighbors swimming in the Long Island Sound and the Atlantic Ocean. On these water-

    ronts there is regular water quality testing and beaches are closed when the water quality ails to meet the

    EPA guideline or sae swimming, or is expected to ail based on historical data and modeling.

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    The popular unoicial beach at Little Stony Point

    Predictive Models Provide

    Real-Time Water Qalit Reportig

    The best practices in water quality monitoring

    include requent testing in all weather condi-tions ollowed by timely public notication

    o the results.

    Once a sucient number o samples has

    been collected at a location, in combination

    with measurements o other environmental

    conditions, a water quality model can be

    developed that enables real-time predictions

    o water quality conditions. This is important

    because the standard tests or sewage

    contamination require an incubation o 24

    hours beore results are available. The use

    o a model allows or predictive, rather

    than reactive, public notication and water

    quality management.

    A good predictive model can take into

    account the actors that impact water quality

    at a given location such as the correlation

    between rainall and sewage/pathogen

    levels, the fow rates and water quality o

    nearby tributaries, turbidity and algae to

    name a ew. Combining these actors with

    historic water quality data, and checking the predictions against real time samples, would enable our

    government agencies to protect public health and close our beaches when the swimming conditions arenot acceptable.

    Predictive water quality models or the Hudson would not be unusual; there are many examples o

    communities that provide timely water quality inormation to the public this way. For example the

    Philly Rivercast system reports water quality on the Schuylkill River in Philadelphia in real time via

    a website www.phillyrivercast.org/. New York State is already using predictive models to manage

    beaches on the Atlantic Ocean and the Long Island Sound.

    The Capital District is considering creating a predictive model or water quality in the Albany Pool

    section o the Hudson using the water quality data gathered during the development o a CSO Long

    Term Control Plan. Assuming that the water quality will be published online or real time use by the

    public, this would be the rst system o its kind on the Hudson River Estuary. We hope more will

    ollow covering all the locations where the public is getting into and enjoying the water.

    A Sigle Sample Stadard Mst Be Adopted o te hdso

    Currently New York State evaluates Hudson River water quality using an average called a geometric

    mean. This approach to averaging greatly reduces the infuence o extremes (very high microbial

    counts and very low microbial counts). While a geometric mean is a useul estimator o long term

    changes to water quality, it does not accurately refect the extreme spikes o sewage contamination that

    HoW IS THE WaTER?

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    Wstewter Irstrctre urdes

    Addressig te Sorce o te Problem

    The early gains in water quality that were achieved in the 1970s ater the passage o the Clean Water

    Act (CWA) are now at risk o being lost because our ederal, state and local governments have not

    continued to maintain and update our wastewater inrastructure. Nationwide sewage contamination

    in our waterways is on the rise.xxiv

    New York State ranks Aging and Inadequate Wastewater Inrastructure as issue #2 on its Top

    10 Water Quality Issues in New York list, right ater Urban Stormwater Runo. The related

    inrastructure issue o ailing sewage treatment systems on personal property, such as septic systems,

    is also on the list - #10 Inadequate Onsite Wastewater Treatment.xxv

    According to the DECs own report, Wastewater Inrastructure Needs o New York, many waste-

    water acilities in NY are past their expected useul lives and maintenance and upgrades at these

    acilities is lagging ar behind where they need to be to keep up with increasing demand. Statewide

    more than 30% o the systems are in excess o 60 years old, while they were designed to last 30 to 40

    years. xxvi The report goes on to make the case or how important a ully unctioning wastewater

    inrastructure is and calls or unding solutions to this worsening problem:

    The importance o modern, reliable, and ecient wastewater treatment systems is sel-evident.

    The health o our communities, the protection o our waterbodies, and the prospects or uture

    economic growth and development, are linked to our ability to maintain, and as necessary,

    upgrade these acilities. As described in this report, however, aged systems are ailing, and

    municipalities do not have the unds to adequately repair and replace the necessary inrastruc-

    ture. There is no disputing that the cost o ensuring proper wastewater treatment is larger than

    what local governments and the state can address on their own. Clearly, there is a compelling

    need or a sustainable wastewater inrastructure unding program, yet no mechanism presently

    exists or that unding, and the ederal government has largely turned its back on the needs o

    the states and local governments or this purpose.

    New York State DEC Inrastructure Workgroup

    are also critically important to track. As average water quality improves, it is the episodic spikes, like

    those ollowing rainall and CSOs that are most important to consider in protecting public health.

    This is why the EPA single sample standard or acceptable water quality is recommended or use at

    recreation waters nationwide and should be employed on the Hudson River Estuary. EPA considers thesingle sample maximum level to be especially important or beaches and other recreation waters that

    are inrequently monitored or prone to short-term spikes in bacteria concentrations, e.g., water that

    may be aected by combined sewer overfow outalls. xxiii

    Riverkeeper urges New York State to adopt the EPA recommended single sample standard or the

    Hudson River in addition to the geometric mean standard and to support county-level high requency

    testing and public notication o water quality at locations where the public is getting into the river.

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    Sewage Overfowig

    at Or Rivertows

    The decline in ederal unding or inrastructure

    upgrades has impacted waterways in every stateacross the nation. However when you compare

    the Hudson River to other locations you get a

    sense o just how overloaded our local wastewa-

    ter system is. For example, in 2010 Westchester

    County alone dumped more sewage into the

    Hudson River as a result o inrastructure ail-

    ures than the entire state o Caliornia dumped

    into the Pacic Ocean that year rom similar

    breaks. Westchesters system dumped upwards

    o 19.5 million gallons o raw and partially

    treated sewage into its rivertown waterronts

    in 2010. Caliornias combined municipal sewersystems dumped less than 15 million gallons

    as a result o inrastructure ailures.xxvii

    Some o the discharge pipes where sewage spills

    occur are situated in newly revitalized waterront

    parks, beaches, kayak launches and marinas.

    For example in Sleepy Hollow millions o

    gallons o sewage fowed rom a pipe near a

    Orangetown and South Rockland sewer districts pipe

    overlowing during rain (an SSO)

    kayak launch at the newly renovated waterront park at Horans Landing in 2010. At the Newburgh

    Launch Ramp sewage overfows are commonplace. There are many other examples o overfows rom

    ailing inrastructure diverting raw sewage to our community waterronts. Its an unwelcome vestige

    o the industrial past o our waterronts.

    Law Eorcemet ad Pblic Egagemet

    In New York State we have yet to muster the political will to use the Clean Water Act to its ull eect

    as an enorcement tool. That law has the stated goals o achieving swimmable and shable rivers that

    are ree o pollution discharges by 1985 across the country. In New York, through good economic times

    and bad, we have continued to issue thousands o permits allowing businesses and municipalities to

    continue discharging pollutants into our waters.

    According to the New York Times 2010 series Toxic Waters on our ailure as a nation to comply with

    the Clean Water Act, there were 10 sewage treatment plants on the Hudson River that had been out o

    compliance with the CWA or more than three years at the time o publishing (Red Hook, Newtown

    Creek, Yonkers, Ossining, New Windsor, Beacon, Poughkeepsie, Hudson, Rensselaer, Waterord).This sad state o aairs will not change until the public and our elected ocials call on the NYS DEC

    to ully enorce the laws that regulate our wastewater systems, requiring private and municipal plants

    to come into compliance with the CWA.

    New York needs a well-unded DEC with public and political support to enorce the Clean Water Act

    and other regulations that protect our shared waters. New housing and business development should

    not be allowed in communities where the local wastewater inrastructure is unable to handle the new or

    HoW IS THE WaTER?

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    existing demands. Our state and ederal governments need to provide unding mechanisms or renewed

    investment in our wastewater inrastructure. Laws governing the installation and maintenance o

    private septic systems must be enacted and enorced.

    pbic ntiicti d Sewe Riht t kw lws

    The key to turning the tide o sewage contamination in the Hudson and elsewhere is public awareness.

    I the public doesnt know that sewage is still being discharged into our rivers and streams, nothing will

    be done to stem the fow. And i we dont know about sewage releases planned, accidental or chronic

    were unable to make an inormed decision about where and when we get in the water.

    More than 20 states have already passed Sewage Right to Know (SRtK) laws that require timely

    public notication o sewage contamination in public waterways. New York is not one o those states.

    Some o the Sewage Right to Know laws in other states only address accidental releases rom inra-

    structure ailures and planned releases or inrastructure repairs. In New York State Riverkeeper

    has proposed a SRtK law that will address both o those, as well as the wet weather releases caused by

    CSOs, and public notication at sites that suer rom chronic sewage contamination. Currently, ithere is a release o raw sewage into the Hudson, no matter how large or how close it is to a recreation

    site, there is no state law requiring public notication.

    In October 2010 a main break caused an estimated 4.4 million gallons o raw sewage to fow into

    the Hudson rom a pipe in the Saw Mill River at Yonkers. While that sewage was fowing groups o

    students rom the Yonkers High School were in the water at the Yonkers waterront, less than mile

    rom the discharge pipe, participating in the DECs annual River Day event. State, county and city o-

    cials all knew about the hazardous sewage in the water but the parents o the students and the teach-

    ers responsible or their saety were unaware. They were deprived o the acts they needed to make an

    inormed decision on behal o their students health and saety that day.

    Two years prior, in October 2008, Westchester County issued a press advisory about a planned release

    o approximately 2 million gallons o sewage connected to a repair at a pump station in Yonkers. That

    advisory was well broadcast and the public took real notice. Riverkeeper sampled the water quality

    in the area the night beore, the morning and aternoon on the day o the release, and then again the

    ollowing morning. Those tests ound Entero counts above the ederal standard, so it was good that

    Westchester issued the warning. However, almost 50% o our water quality samples at the Yonkers

    waterront between 2006 and 2009 had cell counts equal to, or higher than, those measured during

    the planned release. So i the planned release merited a warning to the public, why not the chronic

    unplanned ones?

    I we warn sometimes we should warn all the time because the public has a right to assume that i we

    warn them once, well warn them again when its needed. They airly assume that i there is no warning

    posted then no warning is needed, but in act that is not the case.

    We have to start using the inormation we have at our disposal today to begin warning the public o

    all sewage discharges into the Hudson and other waterways that the public has primary contact with.

    This is what we have come to expect with storm warnings, ozone warnings, trac alerts, boil water

    alerts and even pollen warnings. The systems are in place to get inormation to the public when

    needed, lets add water quality to that list o expected inormation.

    RIvERkEEpER

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    Water Coservatio

    Individuals, towns and businesses can urther reduce the pressure on their sewer system by reducing

    water use. Ater all its not only sewage that fows through our wastewater treatment plants, its also

    the water rom our sinks, showers and in some instances our storm drains and basement sump pumps.Individuals and businesses need to be educated on the importance o water conservation even in non-

    drought situations, improve their water usage habits and implement long-term solutions such as low

    fow sinks and toilets and grey water systems.

    Septic Field Maiteace

    According to the NYS DEC about 25% o New York businesses and residents use onsite sewage treat-

    ment systems such as septic tanks and elds. xxviii When installed and maintained properly they are an

    eective and economical wastewater treatment system. However improper installation, the overuse o

    small systems, an increase in the density o systems, and the widespread lack o proper maintenance has

    turned these systems into a signicant water quality problem, earning them a place on the DECs Top

    10 Water Quality Issues in NYS list. xxix

    Based on the high sewage contamination we have ound coming rom our tributaries, we believe that

    overloaded septic elds could be one o the culprits. Many people install these systems and then orget

    them, not knowing or perhaps not caring when they overload and start to contaminate groundwater

    and surace water with sewage.

    Currently New York State lacks the laws needed to require the inspection and maintenance o private

    septic systems. As a result counties are starting to address the problem with county regulations such as

    the pump out rule that Westchester County put into eect in March 2011. More counties need to ollow

    suit and all businesses and homeowners who have septic systems need to do the right thing and conduct

    regular maintenance.

    Joi Rivereeper ad Spport te Water Qalit Program

    Achieving and maintaining clean water in todays world requires measurement, notication, smart

    planning and investing, good water use habits and vigilance. Riverkeeper is committed to continuing

    our Water Quality Study on the Hudson and expanding our eorts to engage the many capable water

    quality advocates in our communities, and recruiting more to their ranks.

    We encourage you to join this movement!

    Riverkeeper

    20 Secor Road

    Ossining, NY 10562

    [email protected]

    1-800-21-RIVER

    www.riverkeeper.org

    RIvERkEEpER

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    aedix I: Wterbre Iesses d H Heth

    Most waterborne disease-causing microorganisms come rom human and animal ecal waste. A small drop o

    ecal matter can contain millions o microorganisms o many types, some o which are disease-causing pathogens.

    Exposure to the microbial pathogens ound in sewage can lead to short-term and chronic illnesses. xxx

    The most common types o waterborne illnesses are short-term gastrointestinal inections that cause stomach-

    aches and/or diarrhea. The elderly, children, pregnant women, and people with compromised immune systems

    are at greater risk o contracting chronic illnesses rom sewage-contaminated water.

    A survey by the Center or Disease Control reported over 4,000 documented illnesses rom recreational waters in

    the U.S. in 2005-2006. xxxi However this number is assumed to be low because waterborne illnesses are notoriously

    underreported. People oten associate the most common ailments, stomach and digestive system problems, with

    what they ate or lunch instead o contact with water. Still, reports o illness resulting rom swimming are on the rise.

    TyPE AGEnT ACuTE EFFECTS ChROnIC OR uLTIMATE EFFECTS

    Bacteria E. coli O157:H7 Diarrhea Adults: death (thrombocytopenia)

    Legionella pneumoniae Fever, pneumonia Elderly: death

    Helicobacter pylori Gastritis Ulcers and stomach cancer

    Vibrio cholerae Diarrhea Death

    Vibrio vulnifcus Skin & tissue inection Death in those with liver disorders or problems

    Campylobacter Diarrhea Death: Guillain-Barr syndrome

    Salmonella Diarrhea Reactive arthritis

    Yersinia Diarrhea Reactive arthritis

    Shigella Diarrhea Reactive arthritis

    Cyanobacteria (blue-green algae) Diarrhea Potential cancer

    and their toxins

    Leptospirosis Fever, headache, chills, Weils Disease, death (not common)

    muscle aches, vomiting

    Aeromonas hydrophila Diarrhea

    Parasites Giardia lamblia Diarrhea Failure to thrive, Severe hypothyroidism,Lactose intolerance, Chronic joint pain

    Cryptosporidium Diarrhea Death in immune-compromised host

    Toxoplasma gondii Newborn syndrome, Hearing and vision Dementia and/or seizures

    loss, Mental retardation, Diarrhea

    Acanthamoeba Eye inections

    Microsporidia, Diarrhea

    (Enterocytozoon & Septata)

    Viruses Hepatitis viruses Liver inection Liver ailure

    Adenoviruses Eye inections, diarrhea

    Caliciviruses, small round Diarrhea

    structured viruses, Norwalk virus

    Coxsackieviruses Encephalitis, Aseptic meningitis Heart disease (Myocarditis), reactive insulin-

    Diarrhea, Respiratory disease dependent diabetes

    Echoviruses Aseptic meningitis

    APPENDIX

    Sorce: Centers or Disease Control and Prevention. Emerging Inectious Diseases, vol. 3, no. 4, Oct-Dec 1997.

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    aedix II: other ptts i the Hds Rier

    Sewage is just one o the pollutants ound in the Hudson River Estuary. As the pollutant most requently

    linked to waterborne illnesses it is the ocus o Riverkeepers Water Quality Program and Swimmable

    River Campaign.

    Other pollutants ound in the Hudson include PCBs, radioactive contaminants such as tritium and

    strontium-90, nutrients such as nitrogen and phosphorus, heavy metals and a variety o toxins. Some

    o the toxins in the Hudson come rom our wastewater treatment plants, which also treat water rom

    industrial acilities and actories in river communities. Other toxins come rom our bodies and homes,

    via wastewater. These are the byproducts o the medicines, beauty care products, household cleaners,

    disinectants, insecticides and other products we use, many o which are not eciently removed with

    current wastewater treatment technology and thereore end up in the river.

    Our water quality study, and this report, address only microbial sewage pollution.

    aedix III: feder gideies r Etercccs

    We have based our assessment o water quality on the EPA ederal guidelines outlined in the 2000 Beaches

    Environmental Assessment and Coastal Health (BEACH) Act. Unacceptable water is based on an illness

    rate o 19 or more illnesses per 1,000 swimmers in salt water, and 8 or more illnesses per 1,000 swimmers in

    resh water. The concentration oEnterococci(the Entero count) has been correlated to the occurrence

    o swimming related illnesses. The EPA reports Enterococcus counts as colonies (or viable cells) per 100 ml

    o water. xxxii

    There are two standards or water quality in the waters we sample, one or salt or brackish water andone or reshwater.

    Marie Waters

    For saltwater the ederal standard or unacceptable water quality is a single sample value o greater than

    104 Enterococcus cells/100 ml, or ve or more samples with a geometric mean (a weighted average) greater

    than 35 Enterococcus cells/100 ml. We apply this standard to our sampling sites rom NY Harbor in the

    south up to and including Peekskill (northern Westchester and Rockland County) in the north.

    Fres Waters

    For reshwater the ederal standard is a single water sample with a value o greater than 61 Enterococcus

    cells/100 ml, or ve or more samples with a geometric mean greater than 33 Enterococcus cells/100 ml. We

    apply this standard to our sampling sites rom Fort Montgomery north to Waterord.

    APPENDIX

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    aedix Iv: Riereeer Si Site Descritis

    River Mile Name Description

    155.1 Hudson above Mohawk River The Hudson River, above the lock at Troy, is no longer part o the

    estuary. This site has boating, kayaking, recreational and subsistence

    shing, and occasional swimming.

    155 Mohawk River This site is below the last Erie Canal lock. It has boating, kayaking,

    subsistence and recreational shing rom boats and the shore. There is

    also occasional swimming.

    152.5 Hudson River above Troy Lock This site has boating, kayaking and shing. The Waterord drinking

    water intake is in the vicinity.

    151.5 Congress Street Bridge This site has boating and kayaking as well as recreational and subsis-

    tence shing rom boats and shore.

    146 Albany Rowing Dock At the Albany Rowing Dock, there is water contact rom kayaking,

    team rowing, recreational boating and shing.144.5 Dunn Memorial Bridge In the heart o the port o Albany, contact includes kayaking, team

    rowing, and swimming rom recreational boats. The site also has sh-

    ing rom shore and rom boats.

    142 Island Creek/Normans Kill The two creeks enter the Hudson at this sampling site. There are no

    acilities, but there is recreational boating and some kayaking through

    the industrial portion o the Port o Albany.

    138 Bethlehem Launch Ramp The Bethlehem Launch Ramp has kayaking, recreational boating, and

    shing rom boat and shore.

    137 Castleton, Vlockie Kill Near the mouth o Vlockie Kill this site has recreational

    boating, kayaking and shing rom vessels and the shore.

    133 Coeymans Landing This sampling site is at a village park that has a shing pier,

    a marina, and a launch ramp or kayaks.

    124 Coxsackie Waterront Park The park at Coxsackie has an unocial beach, a launch ramp and a

    shing area. Kayaking, recreational boating, and casual water contact

    occur here.

    122.5 Gays Point mid-channel A state park with camping, recreational boating and swimming is di-

    rectly east o this sample site. It is a relatively undeveloped portion o the

    estuary.

    117 Athens STP Outall The Athens Sewage Treatment Plant Outall is in close

    proximity to the village waterront, which has recreational boating

    rom small marinas, kayaking, and shing.

    116.5 Hudson Launch Ramp The launch ramp and boat club at Hudson host kayaking,

    shing and recreational boating. There is swimming in the area.

    113.2 Catskill Creek, First Bridge Near the rst bridge over the Catskill Creek, there are marinas, recre-

    ational boat trac, kayaking and shing. There is

    swimming in the vicinity.

    113.1 Catskill Creek, East End Near the entrance o the Catskill Creek, this sampling site has recre-

    ational boating, kayaking, shing, and swimming.

    113 Catskill Launch Ramp The Launch Ramp at Catskill has kayaking, casual water contact rom

    recreational boats, and shing.

    APPENDIX

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    River Mile Name Description

    108.5 Inbocht Bay This sampling site has recreational boating, kayaking, and shing.

    103 Malden Launch Ramp There is a sewage treatment plant outall near this public launch ramp,

    which has kayaking, shing, and casual water contact rom recreation-

    al boats and jet skis.

    102.1 Esopus Creek West This site has boating, kayaking, occasional swimming and shing. There

    is a sewage treatment plant outall nearby to the west.

    102 Esopus Creek Entrance Just in rom the lighthouse, there is kayaking, boating, and

    occasional swimming and shing.

    99 Tivoli Landing There is an unocial kayak launch rom the rocky shore, as well as

    boating and shing.

    97 Ulster Landing Beach This ocial beach has water contact rom swimming and

    kayaking, as well as some shing in the vicinity.

    92.3 Eddyville Anchorage This site in Rondout Creek is heavily used or boating, kayaking, rat-

    ing, swimming and shing.

    92.2 Kingston Public Dock The town docks o Kingston and West Strand Park host a marina,

    recreational boating, shing and kayaking on Rondout Creek. There is

    a combined sewer overfow (CSO) at the site.

    92.1 Kingston STP Outall The sewage treatment plant discharges into Rondout Creek at Kings-

    ton. Rondout Creek is heavily used or boating, tubing, team rowing,

    kayaking and shing.

    92 Kingston Point Beach This ocial beach has swimming, shing rom the shoreline, kayaking

    and recreational boating in the vicinity.

    88 Port Ewen drinking water intake The drinking water intake at Port Ewen is used by a number o com-

    munities. Use o the area includes shing rom boats and rom shore,

    boating, kayaking and swimming.

    85 Norrie Point Yacht Basin The yacht basin is located at the mouth o a small tributary. There is

    boating, kayaking and shing.

    84.5 Norrie Point mid-channel This deep-water site has boating, kayaking and shing.

    77 Poughkeepsie drinking water intake This area has boating, kayaking, team rowing, and shing.

    75 Poughkeepsie Launch Ramp This site has a launch ramp, boating, kayaking, shing, and some

    swimming rom boats.

    68 Marlboro Landing The landing at Marlboro has a marina, as well as kayaking, shing,

    and swimming rom boats. There is a tributary in close proximity.

    66.5 Wappingers Creek This sample site has swimming rom recreational boats, kayaking andshing.

    61 Beacon Harbor The Beacon Harbor sampling site has recreational boating, kayaking,

    and shing. There is a seasonal public river pool to the north, and a

    storm drain overfow in the vicinity.

    60 Newburgh Launch Ramp This area is heavily used or boating, kayaking and jet skis, with team

    rowing and shing in the vicinity. Next to the ramp is a combined

    sewer overfow (CSO) and a ew hundred yards south is a sewage

    treatment plant outall.

    APPENDIX

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    River Mile Name Description

    54 Little Stony Point At Little Stony Point there is an unocial swimming beach, as well

    as recreational boating, kayaking, and shing.

    53.5 Cold Spring Harbor The town docks o Cold Spring host a shing pier, a yacht club, and a

    village waterront where shing, kayaking, and recreational boating are

    all sources o human contact with the water.

    52.5 West Point STP Outall This area is used or boating, kayaking, team rowing and shing.

    46 Fort Montgomery This site has recreational boat trac, shing and kayaking. A small

    sewage treatment plant discharges here as well.

    44 Annesville Creek Annesville Creek is a tributary near Peekskill that is popular with kayakers.

    43 Peekskill Riverront Green Park At this site there is a launch ramp, boating, kayaking and shing.

    Swimming at the beach nearby is prohibited but casual contact with

    the water has been observed.

    40.5 Stony Point mid-channel This deep-water sampling site has boating, kayaking and shing.

    40 Cedar Pond Brook Cedar Pond Brook is a tributary that has boating, kayaking and shing.

    39 Emeline Beach Swimming at the beach at Emeline Park is prohibited, yet casual con-

    tact with the water has been observed. The site has shore-based shing,

    kayaking and recreational boating.

    38 Furnace Brook The Hudson, o Furnace Brook, has recreational and subsistence

    shing, as well has kayaking, and swimming rom recreational boats.

    35.5 Haverstraw Bay mid-channel Near the ship channel in Haverstraw Bay, this deep-water sampling site

    has recreational boating and shing.

    35 Croton Point Beach Croton Point Park has a designated public swimming beach, operated

    by Westchester County. There is also a high volume o recreational

    boats, kayaking and shing.

    34 Ossining Beach Swimming at Ossining beach is prohibited, yet casual contact with the

    water has been observed. The beach is immediately north o a sewage treat-ment plant outall. There is shing, boating and kayaking at this site.

    28.1 Nyack Launch Ramp This public launch ramp is adjacent to a waterront park, village

    marina and private boat club. There is boating, kayaking, windsurng

    and jet skiing, as well as shing and some swimming.

    28 Kingsland Pt., Pocantico River This beach, located at a public park in Sleepy Hollow, was once a pub-

    lic swimming beach and the bathhouse remains however swimming is

    now prohibited. A small private boat club and ocial swimming beach

    are approximately 400 yards north o the sample site. Site uses include

    boating, kayaking, shing.

    27.5 Tappan Zee Bridge mid-channel This deep-water site at the Tappan Zee Bridge has boating, kayaking

    and shing.

    27 Tarrytown Marina This large marina has boating and shing.

    26.5 Upper Sparkill Creek At this tributary there is canoeing, kayaking and shing.

    26.1 Piermont Pier Piermont Pier is used heavily or recreational and subsistence shing

    and crabbing. There is also boating and kayaking.

    26 Piermont STP Outall There are two sewage treatment plant outalls at this sampling site. Use

    includes boating, kayaking and shing.

    APPENDIX

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    River Mile Name Description

    25.9 Irvington Beach This beach is located between a boat club and a village park. The site

    has kayaking, casual water contact, recreational boating and shing.

    Theres a combined sewer outfow (CSO) approximately 100 yards to

    the south.

    18.5 Yonkers mid-channel This deep-water site has boating and shing.

    18.4 Saw Mill River The Saw Mill River enters the Hudson at Yonkers. There is boating,

    kayaking, recreational and subsistence shing in this area.

    17.5 Yonkers STP Outall This wastewater treatment plant treats sewage rom much o Westchester

    County. The area has boating, kayaking and shing.

    14 Dyckman St. Beach The sample site at Inwood Hill Park has shing, kayaking, team rowing,

    recreational boating and casual water contact at the beach. There is a

    combined sewer overfow (CSO) under the pier at this site.

    12.1 Harlem River, Wash. Ave. Bridge The Harlem River at the Washington Avenue Bridge is an industrial

    waterway connecting the Hudson with the East River. Contact include

    recreational boating and jet skiing, kayaking, as well as recreationaland subsistence shing rom the shore. There is increasing activity

    rom community and college crew teams.

    12 GW Bridge mid-channel This deep-water sample site at the George Washington Bridge has

    recreational boating, jet-skiing, kayaking and occasional swim events.

    8.1 Harlem River, Willis Ave. Bridge The Harlem River at the Willis Avenue Bridge is an industrial water-

    way, connecting the Hudson with the East River. Contact includes

    recreational boating and jet skiing, kayaking, as well as recreational

    and subsistence shing rom the shore.

    8 125th St. STP Outall The Hudson in the vicinity o this wastewater treatment plant has

    recreational boating, kayaking and shing.

    7.9 125th St. Pier The Pier at 125th St. is a new access point or recreational and sub-

    sistence shing. There is a New York City combined sewer overfow(CSO) immediately to the south.

    7 79th St. mid-channel This deep-water sample site o 79th St. has recreational boating and

    occasional swim events.

    6 Pier 96 Kayak Launch The Kayak Launch at Pier 96 is in the vicinity o New York City

    combined sewer overfows (CSOs).

    4.7 Castle Point, NJ This sample site is located at the HRECOS research buoy o the

    Stevens Institute o Technology in Hoboken, New Jersey.

    4 East River at Roosevelt Island This site has boating, shing, kayaking and occasional swim events.

    2.7 Newtown Creek, Metro. Bridge Newtown Creek at the Metropolitan Avenue Bridge is an industrial

    waterway and a tributary o the East River.

    2.6 Newtown Creek, Dutch Kills Newtown Creek at Dutch Kills is a tributary where subsistence shing,as well as increasing kayak activity has been observed.

    2.5 East River mid-channel 23rd St. The deep-water sampling site around 23rd St. has mostly transitory

    boat trac.

    0.1 The Battery mid-channel The deep-water sample site at Battery Park has recreational boat trac,

    as well as some kayaking and occasional swim events.

    -1 Gowanus Canal The Gowanus Canal is an industrial waterway with limited dockage or

    recreational boats, and some kayaking and canoeing.

    APPENDIX

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    Edtes

    i We have based our assessment o acceptable water quality on the ederal guidelines outlined in the

    2000 Beaches Environmental Assessment and Coastal Health (BEACH) Act. There are two ederal

    standards or water quality in the waters we sample, one or salt water and one or reshwater. SeeAppendix III or EPA guidelines.

    ii Dorman, M. and K.S. Rosselot. Testing the Waters: A Guide to Water Quality at Vacation

    Beaches, Natural Resources Deense Council, New York, NY, 2010, p. 5.

    iii Lawler, Matusky & Shelly Engineers, The Hudson Group, Swimming in the Hudson River Estu-

    ary: Feasibility Report on Potential Sites, Hudson River Estuary Program, New York State De-

    partment o Environmental Conservation, 2005, p. 16. http://www.dec.ny.gov/lands/5452.html

    iv Dorman, M., and K.S. Rosselot, p. 9.

    v Ibid.

    vi

    Hewes, W., and K. Baer. Whats In Your Water? The State o Public Notication in 11 U.S. States,American Rivers, Washington D.C., 2007, p. 7. http://www.americanrivers.org/assets/pds/reports-

    and-publications/arswg-all-8_16_07_opta842.pd

    vii NYC Green Inrastructure Plan: A Sustainable Strategy For Clean Waterways, Department o

    Environmental Protection, New York, NY, 2010, p. 8. http://home2.nyc.gov/html/dep/pd/

    green_inrastructure/NYCGreenInrastructurePlan_HighRes.pd

    viii Riverkeeper survey o county water quality testing in the Hudson River Estuary, 2010.

    ix New York Harbor water quality reports are available online http://www.nyc.gov/html/dep/html/

    news/hwqs.shtml

    x For more inormation on our science partners visit http://www.riverkeeper.org/water-quality/

    hudson/our-partners/

    xi Method 1600: Enterococciin Water by Membrane Filtration Using membrane-Enterococcus Indox-

    yl-$-D-Glucoside Agar (mEI), U.S. Environmental Protection Agency, Washington D.C., 2002, p. 1.

    xii Riverkeeper characterizes our water quality samples into three categories: acceptable, unacceptable

    and possible risk. Acceptable: meets EPA single sample guideline or sae swimming. Unaccept-

    able: ails EPA single single sample guideline or sae swimming. Possible risk: meets single sample

    guideline, but would ail geometric mean guideline i sustained over time.

    xiii We have shore-based sites where we collect samples at higher requency (e.g. Sparkill Creek). Since

    the sampling dates and requency or the shore-based stations dier rom the monthly patrol boat

    sampling, these sites have been excluded rom regional analyses. However, data rom these sites is

    available on the project website www.riverkeeper.org/water-quality/locations

    xiv 24,200 is the maximum Ent